August 25, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

 Inspire 1 User Manual

 Inspire 1 Quick Start Guide

 Inspire 1 Maintenance Manual

These attachments are too large to submit via the submission portal. They are available

for download at this website- http://www.dji.com/product/inspire-1/download

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform act of 2012 and 14

C.F.R. Part 11, Sunflower Unmanned Solutions LLC, referred to hereafter as the petitioner,

hereby requests exemption from the following sections of Title 14, Code of Federal Regulations14 C.F.R. 61.113(a)&(b);

14 C.F.R. 91.7(a);

14 C.F.R. 91.119(c);

14 C.F.R. 91.121;

14 C.F.R. 91.151(a)(1);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a) (1);

14 C.F.R. 91.409(a) (2);

14 C.F.R. 91.417(a)&(b).

In order to provide commercial services by use of unmanned aircraft systems (UAS) at the

highest level of safety. Commercial services to be provided through the use of a small unmanned

aircraft would be:

• Aerial photography/ videography

• Agriculture

• Mapping

• Inspections

• Real Estate

• Wildlife and forestry monitoring

• News gathering

• Emergency response assistance
• Research and training

• Other flight operations

The petitioner's goal with this exemption is to gain legal access to the National Airspace System

while also maintaining the highest level of safety for these services.

The UAS

This exemption would allow the petitioner to operate one DJI Inspire 1. This aircraft is a

four motor, quad copter configuration that weighs roughly 3 kilograms (2,935 grams), which

falls into the category of small UAS, and measures 17.3x11.8x17.7 inches. Maximum speed is

22 m/s, or 42.8 knots, while the maximum ascent speed is 5 m/s and the descent speed reaches 4

m/s. Ground to air communication is accomplished through a 2.4 GHz frequency from a master

transmitter that is in compliance with FCC regulations. The DJI Inspire 1 utilizes a brand new

flight controller built specially for the aircraft. This flight controller allows the aircraft to record

its "home point", or location at takeoff, which insures a failsafe in the event of an unscheduled

in-flight emergency- i.e. lost transmitter signal- that would enable the aircraft to automatically

return to its home point and land. This intelligent flight controller is also capable of having flight

limits and flight restriction areas. These restrictions prevent the aircraft from flying past a

predetermined altitude and distance from the operator, as well as preventing any flights from

occurring in "no-fly zones", which are areas of high air traffic or national security.

Risk Management

The petitioner is trained with the right tools to mitigate risk and operate in a safe manner

while ensuring public safety. The pilot in command (PIC) holds a current private pilot license

with instrument rating along with a current second class medical certificate and has a high level

of knowledge of the National Airspace System (NAS). This operator is also highly educated in

unmanned aircraft systems as he is enrolled in one of the top UAS programs in the country. The

PIC also has over 30 (32) hours of pilot in command time of multirotor platforms, including 8

hours in the DJI Inspire 1 aircraft. Pre-flight, in-flight, and post-flight checklists will be utilized

in each mission, as well as safety briefings for crew members before each flight. A risk

assessment matrix will be completed before each flight as well to ensure that not only is the

aircraft in a condition safe for flight, but that factors such as weather and crewmembers are

assessed before flight as well. A visual observer (VO) will be used during all flight operations,

and will remain within unaided audio range of the PIC. All flight times will be logged along with

the aircraft's flight characteristics, and any changes to flight critical components will be noted

and reported to the FAA. All manufacturer recommended maintenance checks will performed

and logged in order to ensure the proper steps are being taken to maintain the aircraft in a

condition that is safe for flight.

All flight operations would also be subject to the following guidelines:

 Flight times would be limited to 30 minutes, or 25% of remaining capacity of battery,

whichever comes first

 Minimum crew for operations would consist of one PIC and one VO

 Operations will not exceed 400 feet above ground level (AGL)

 Operations will be conducted during daylight hours only

 Aircraft will remain within visual line of sight of the PIC and VO at all times
 Flights will not occur when weather minimums are not met (500 feet below or 2,000 feet

horizontally from a cloud and at least 3 statute miles of visibility from the operator)

 Operations will not occur within 5nm of any airport unless a letter of agreement with that

airport's management is obtained and the appropriate communication is made with said

persons prior to the flight

 All documents mentioned in this exemption request, also referred to as the operating

documents, will be made available along with the grant of exemption to the

Administrator and any law enforcement personnel upon request

Operations of the Unmanned Aircraft

Before operating on and over private property, the petitioner will obtain landowner's

permission. All operations will be conducted at least 500 feet from non-participating people to

ensure the public's safety is not compromised. In the event that the 500 foot radius is in jeopardy

from non-participating persons, vessels, vehicles and structures, the PIC will immediately cease

flight operations in order to preserve the safety of said subjects. The operator's high knowledge

of the surrounding NAS will aid in maintaining a high level of safety when communicating with

local air traffic controllers before flights. In regards to the area of operations, two exemptions

have been granted to organizations operating in similar environments, referring to exemption

number 11741 (Witt Tech LLC) and exemption number 11172 (Blue-Chip UAS). These

organizations have safely and successfully been integrated into the NAS and have operated in

similar environments, as well as a similar geographical area (in regards to the local environment)

to that the petitioner is requesting. The petitioner also finds many similarities with other

exemptions that have been granted, in particular exemption number 11881 (Empire Unmanned

LLC), which operates the same aircraft as the petitioner and is involved in the same, if not very

similar, flight operations as the petitioner is petitioning to conduct. The petitioner finds that

because of the similarities in all facets of its own exemption and those mentioned as being

granted above, it is feasible to grant Sunflower Unmanned Solutions LLC its request for

exemption.

Public Interest

As a relatively new industry, UAS is still in its beginning stages of economic growth. As

a small, local business, Sunflower Unmanned Solutions LLC would be able to create new

possibilities within the area for this industry. Not only would this exemption permit the petitioner

to boost the local economy, it would also allow the petitioner to effectively promote the safe use

of unmanned aircraft systems to its clients and, as a result, the community as a whole. The strict

operating procedures that would be upheld by the petitioner would result in operations being

performed at an equivalent level of safety as manned aircraft operate. All services being

conducted would allow a less expensive operation while still maintaining the FAA's safety

standards for manned aviation.
Exemption Requests and Equivalent Level of Safety

14 C.F.R. § 61.113 Private pilot privileges and limitations: Pilot in command.

The regulation provides that no person that holds a private pilot certificate may act as

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a

private pilot to act as pilot in command of an aircraft in connection with any business or

employment if: (1) The flight is only incidental to that business or employment; and (2)

The aircraft does not carry passengers or property for compensation or hire.

Equivalent Level of Safety

Currently, there are no applicable areas identified for aircraft in either the private or

commercial sector and therefore an exemption is required to conduct commercial

operations. As flight operations will be conducted in a contained environment, these strict

guidelines will achieve an equivalent level of safety for each individual flight when compared to

commercial flights identified in Part 61 when originally developed.

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil

aircraft be in airworthy condition to be operated. Inasmuch there will be no airworthiness

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory

standard will exist for determining airworthiness.

Equivalent Level of Safety

Given the size of the DJI Inspire 1 and the preflight procedures, including all logbooks, preflight

checklists, and maintenance checks, an equivalent level of safety will be provided to ensure the

aircraft is in an airworthy condition for flight operations.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes

Petitioner requests an exemption from the minimum safe altitude requirements of 14

C.F.R. § 91.119(c) which states that aircraft may not operate closer than 500 feet above

the surface and away from any person, vessel, vehicle, or structure in non-congested

areas. To provide the intended operations, the aircraft is operated below 400 feet AGL.

Equivalent Level of Safety

Compared to flight operations with manned aircraft that far outweigh the Inspire 1, and given the

lack of flammable fuel, any risk associated with these operations is far less than those that

presently exist with conventional aircraft. An equivalent level of safety will be achieved given

the size, weight, and speed of the UAS, as well as the location where it is operated. As set forth

in the operations section of this exemption, the UAS will be operated away from densely

populated areas and at least 5nm away from airports (unless a letter of agreement from the

airport’s management is obtained), where buildings and people will not be at risk of any incident

or accident. Because of the advance notice to the property owners and participants, all affected

individuals will be aware of the planned flight operations.
14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person

operating an aircraft to maintain cruising altitude or flight level by reference to an

altimeter that is set to the elevation of the departure airport or barometric pressure. An

exemption is required because the UAS does not have a barometric altimeter, but rather

a GPS altitude indicator.

Equivalent Level of Safety

An equivalent level of safety will be achieved by the operator confirming the altitude of

the launch site before flight as shown on the GPS altitude indicator. The PIC will also

use the GPS altitude indicator to continuously monitor the aircraft's height, ensuring

operation at safe altitudes.

14 C.F.R. § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

Petitioner requests an exemption from 14 C.F.R. § 91.151(a)(1)'s fuel requirements for

flight in VFR conditions during the day. Section 91.151(a)(1) states:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering

wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed –

(1) During the day, to fly after that for at least 30 minutes;

The battery powering the Inspire 1 provides approximately 22 minutes of flight. To

meet the 30 minutes reserve requirement in 14 C.F.R. § 91.151, flights could not

be conducted. Given the limitations on the aircraft's proposed flight area and the location

of its proposed operations within a predetermined area, a safety margin based on a

reserve amount of battery life is needed.

Equivalent Level of Safety

An equivalent level of safety will be achieved as flight operations will be limited to visual line of

sight, requiring the operations to be conducted on site thus limiting any transit time of the

aircraft. All flights will be terminated with no less than 25% reserve battery power still available

as stated in the Risk Management section of this request. This restriction would be more than

adequate to return the aircraft safely to the ground and its planned landing zone from anywhere

in its limited operating area even in the event of an unexpected occurrence. Operation of the

aircraft with less than 30 minutes of reserve fuel does not include the type of risks that Section

91.151(a)(1) was intended to alleviate given the size and speed of the petitioner's UAS, and the

proximity of the flight operation to the landing zone.
14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance

Inspections

Petitioner also seeks an exemption from requirements contained in 14 C.F.R. § 91.405(a),

91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and

inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating

that each owner or operator of an aircraft "[s]hall have the aircraft inspected as prescribed in

subpart E of this part and shall between required inspections ...have discrepancies repaired as

prescribed in part 43 of this chapter"). An exemption to these regulations is needed because Part

43 and these sections only apply to aircraft with an airworthiness certificate, which the aircraft

will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because the operator will ensure that the

aircraft is in working order prior to initiating flight by following the appropriate checklists and

logs as discussed in the Risk Management section of this request. The operator is the person

most familiar with the particular aircraft and best suited to maintain the aircraft in an airworthy

condition.

Concluding Statement

Sunflower Unmanned Solutions LLC seeks an exemption from the aforementioned FARs

in order to conduct safe, legal, and efficient commercial operations using one DJI Inspire 1.

The petitioner finds that its operating procedures are of at least an equivalent level of

documented safety as all exemptions granted before the date of submission. Given the Inspire 1's

size, weight, speed, flight capabilities, operation within visual line of sight, lack of proximity to

airports and populated areas, and national security, all criteria as set forth in Section 333 of the

Reform Act have been satisfied. It is under these circumstances that the petitioner finds adequate

justification for its request for exemption to be granted, and thus respectfully submits this letter

for approval.

Best Regards,

Spencer Schrader

Sunflower Unmanned Solution, LLC

SunflowerUnmannedSolutions@gmail.com

785-577-3417

800 South Santa Fe, Salina, KS 67401